Gibbons v. Ogden

The Facts

The New York legislature granted Livingston and Fulton the sole right of navigation on its state waterways. Livingston gave defendant the exclusive right to navigate the waters between New York City and New Jersey.

Defendant originally sued plaintiff, requesting the court to keep Plaintiff from navigating the waters that he had exclusive right to.  Defendant won in court, holding that he had sole right to navigate the waterways.  Plaintiff appealed on the grounds that Congress had authorized his steamship navigation of the water ways entitled “An act for enrolling and licensing ships and vessels to be employed in the coasting trade and fisheries, and for regulating the same.” Plaintiff argued at court the act procured by Congress was superior, via the Supremacy Clause.  He further contended that not considering Congressional interstate commerce laws supreme would result in confusing and contradictory regulatory policies proffered at the federal level.

The case was appealed to the Supreme Court.

The Issue

Whether a state has the power to pass a law that impacts interstate commerce, where the law directly contravenes existing Congressional statute.

The Holding/Reasoning

No, reversed. The laws of Congress regulating interstate commerce are supreme.  The interstate commerce clause is to be interpreted broadly.  It means the power to regulate any and all commerce over waterways between states.  This includes the power to regulate pure navigation, even for transportation’s sake where no commerce directly occurs.  Navigation, under broad interpretation by Justice Marshall, is commerce.  The constitution places no limitations on the power to regulate interstate commerce; therefore, it shall be interpreted broadly.  Because Congress is granted the exclusive right to regulate interstate commerce, it is presumed to not be a power vested in the states.  And where a law of Congress and a law of the state are in conflict, Congressional law reigns supreme via the power granted by the Constitution in the interstate commerce clause.  The interstate commerce power of Congress, however, does not extend to activities confined exclusively within a state’s boundaries.

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